Know About the DFARS Interim Rule 11/30/20 Deadline re: CMMC Compliance?


DoD is issuing an interim rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to implement a DoD Assessment Methodology and Cybersecurity Maturity Model Certification (CMMC) framework in order to assess contractor implementation of cybersecurity requirements and enhance the protection of unclassified information within the DoD supply chain.


Effective November 30, 2020.

Comments on the interim rule should be submitted in writing to the address shown below on or before November 30, 2020, to be considered in the formation of a final rule.


Submit comments identified by DFARS Case 2019-D041, using any of the following methods:

Federal eRulemaking Portal: Search for “DFARS Case 2019-D041”. Select “Comment Now” and follow the instructions provided to submit a comment. Please include “DFARS Case 2019-D041” on any attached documents.

Email: Include DFARS Case 2019-D041 in the subject line of the message.

Comments received generally will be posted without change to, including any personal information provided. To confirm receipt of your comment(s), please check, approximately two to three days after submission to verify posting.


  1. Background

The theft of intellectual property and sensitive information from all U.S. industrial sectors due to malicious cyber activity threatens economic security and national security. The Council of Economic Advisors estimates that malicious cyber activity cost the U.S. economy between $57 billion and $109 billion in 2016. Over a ten-year period, that burden would equate to an estimated $570 billion to $1.09 trillion dollars in costs. As part of multiple lines of effort focused on the security and resiliency of the Defense Industrial Base (DIB) sector, the Department is working with industry to enhance the protection of unclassified information within the supply chain. Toward this end, DoD has developed the following assessment methodology and framework to assess contractor implementation of cybersecurity requirements, both of which are being implemented by this rule: the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 DoD Assessment Methodology and the Cybersecurity Maturity Model Certification (CMMC) Framework. The NIST SP 800-171 DoD Assessment and CMMC assessments will not duplicate efforts from each assessment, or any other DoD assessment, except for rare circumstances when a re-assessment may be necessary, such as, but not limited to, when cybersecurity risks, threats, or awareness have changed, requiring a re-assessment to ensure current compliance.

  1. NIST SP 800-171 DoD Assessment Methodology

DFARS clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, is included in all solicitations and contracts, including those using Federal Acquisition Regulation (FAR) part 12 commercial item procedures, except for acquisitions solely for commercially available off- the-shelf (COTS) items. The clause requires contractors to apply the security requirements of NIST SP 800-171 to “covered contractor information systems,” as defined in the clause, that are not part of an IT service or system operated on behalf of the Government. The NIST SP 800-171 DoD Assessment Methodology provides for the assessment of a contractor’s implementation of NIST SP 800-171 security requirements, as required by DFARS clause 252.204-7012. More information on the NIST SP 800-171 DoD Assessment Methodology is available at​dpap/​pdi/​cyber/​strategically_​assessing_​contractor_​implementation_​of_​NIST_​SP_​800-171.html.

The Assessment uses a standard scoring methodology, which reflects the net effect of NIST SP 800-171 security requirements not yet implemented by a contractor, and three assessment levels (Basic, Medium, and High), which reflect the depth of the assessment performed and the associated level of confidence in the score resulting from the assessment. A Basic Assessment is a self-assessment completed by the contractor, while Medium or High Assessments are completed by the Government. The Assessments are completed for each covered contractor information system that is relevant to the offer, contract, task order, or delivery order.

The results of Assessments are documented in the Supplier Performance Risk System (SPRS) at​ to provide DoD Components with visibility into the scores of Assessments already completed; and verify that an offeror has a current (i.e., not more than three years old, unless a lesser time is specified in the solicitation) Assessment, at any level, on record prior to contract award.

Emory Vandiver

Emory Vandiver is the Vice President of Business Operations and a Partner at Interactive Security, where he is responsible for executing the company's strategy as a premier IT Security and Compliance provider. For over 20 years Emory has worked for leading enterprises across a diverse cross section of the information technology industry. His professional passion lies in understanding client business goals, challenging the status quo and leveraging technology-based solutions to maximize client performance. He strives to bring unique insight and value to his clients' businesses, along with a superior customer experience.